It is a widely known fact that a person who is accused of a crime, such as a DUI, is innocent until proven guilty. In Pennsylvania DUI cases, the rule of corpus delicti places the burden on the State of proving a crime has been committed before a defendant’s admission can be admitted into evidence against as proof of a commission of a crime. Recently, the Superior Court of Pennsylvania discussed corpus delicti in a DUI case in which it was disputed whether the State had introduced sufficient evidence to allow the defendant’s admission of driving while intoxicated to be admitted into evidence. If you were recently charged with a Pennsylvania DUI despite a lack of direct evidence or you committed a crime, you should speak with an experienced Pennsylvania DUI defense attorney regarding your available defenses.
Facts Surrounding the Defendant’s Arrest and Subsequent Trial
Reportedly, the defendant was asleep in the passenger seat of his truck when it rolled into the roadway. The defendant was alone in the truck and the keys were in the ignition. The defendant awoke when the police were knocking on the passenger window. The police noticed a strong odor of alcohol on the defendant and his slurred speech. Additionally, the defendant stated he was the driver of the vehicle and that he consumed alcohol. He was subsequently charged with DUI and careless driving.
It is reported that prior to the trial the defendant filed a motion to preclude evidence of his admission of drinking and driving, due to the State’s lack of evidence a crime was committed. The court denied his motion. The defendant was convicted on both counts, after which he appealed. On appeal, the defendant argued that under the rule of corpus delicti, the trial court erred in denying his motion because the State failed to show that it was more likely than not that a crime occurred. Further, he argued there was insufficient evidence to show he was guilty of DUI.
Corpus Delicti Under Pennsylvania Law
Corpus delicti is an evidentiary rule which occurs in two phases: in the first phase, the State must prove a crime has been committed by a preponderance of the evidence. If the State shows it is more likely than not that a crime has been committed than a defendant’s confession is admissible. In the second phase, which occurs after a confession has been admitted into evidence, the State must prove beyond a reasonable doubt the defendant committed the crime for which he or she is charged. Stated another way, the State does not have to prove beyond a reasonable doubt that a crime has been committed, but the evidence must show that it is more likely that a crime was committed. Further, the State can establish a crime has been committed via circumstantial evidence. The State cannot obtain a conviction based solely on incriminating statements of the defendant, however.
Here, the court found that the weight of the circumstantial evidence was sufficient to show that a crime had been committed. Specifically, the defendant was the only one in the vehicle, which was registered in his name and parked outside of an establishment that did not serve alcohol. Further, he allegedly showed clear signs of intoxication. As such, the court found the trial court did not err in denying the defendant’s motion and upheld his conviction.
Speak with a Seasoned Pennsylvania DUI Attorney
If you are charged with a Pennsylvania DUI it is in your best interest to meet with a seasoned Pennsylvania DUI attorney to discuss the facts of your case and what evidence the State may introduce against you at trial. Attorney Zachary B. Cooper is an experienced DUI defense attorney who will set forth an assertive defense on your behalf. Mr. Cooper can be reached at (215) 542-0800 to schedule a meeting.